Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Income Tax: Section 47(iii) of the Income Tax Act, which exempts transfers of capital assets under gift, will or irrevocable trust from capital gains tax, is proposed to be amended. The amendment aims to limit the exemption to individuals and Hindu Undivided Families, effectively making such transfers by companies taxable. This move intends to curb tax avoidance and erosion of the tax base through gifting of shares by companies, which has been a litigated issue. The amendment will be effective from April 1, 2025, applicable for Assessment Year 2025-26 onwards.
Income Tax: Section 47(iii) of the Income Tax Act, which exempts transfers of capital assets under gift, will or irrevocable trust from capital gains tax, is proposed to be amended. The amendment aims to limit the exemption to individuals and Hindu Undivided Families, effectively making such transfers by companies taxable. This move intends to curb tax avoidance and erosion of the tax base through gifting of shares by companies, which has been a litigated issue. The amendment will be effective from April 1, 2025, applicable for Assessment Year 2025-26 onwards.
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